Bravo v. Treasurer of Puerto Rico

Mr. Justice Pérez Pimentel

delivered the opinion of the Court.

The Mayagüez Sugar Company was the owner of a certain property which it divided into several parts selling it to different persons. One of the purchasers was John M. Bravo, who, since 1944 when he bought it until now, has been using his property for the planting of sugar cane. In his business, Bravo keeps his accounts on the accrual basis.

In his 1945 income tax return Bravo reported certain losses during that fiscal year. As part of the income reported for that year he included the amount of .$21,838.22 as a subsidy from the Federal…